Data processing systems for prioritizing data subject access requests for fulfillment and related methods

ABSTRACT

In various embodiments, a data subject request fulfillment system may be adapted to prioritize the processing of data subject access requests based on metadata of the data subject access request. For example, the system may be adapted for: (1) in response to receiving a data subject access request, obtaining metadata regarding the location from which the data subject access request is being made; (2) using the metadata to determine whether a priority of the data subject access request should be adjusted based on the obtained metadata; and (3) in response to determining that the priority of the data subject access request should be adjusted based on the obtained metadata, adjusting the priority of the data subject access request.

CROSS REFERENCE TO RELATED APPLICATIONS

This application is a continuation-in-part of U.S. patent applicationSer. No. 16/357,260, filed Mar. 18, 2019, which is a continuation ofU.S. patent application Ser. No. 16/054,762, filed Aug. 3, 2018, nowU.S. Pat. No. 10,235,534, issued Mar. 19, 2019, which claims priorityfrom U.S. Provisional Patent Application Ser. No. 62/547,530, filed Aug.18, 2017, and which is also a continuation-in-part of U.S. patentapplication Ser. No. 15/996,208, filed Jun. 1, 2018, now U.S. Pat. No.10,181,051, issued Jan. 15, 2019, which claims priority from U.S.Provisional Patent Application Ser. No. 62/537,839 filed Jul. 27, 2017,and is also a continuation-in-part of U.S. patent application Ser. No.15/853,674, filed Dec. 22, 2017, now U.S. Pat. No. 10,019,597, issuedJul. 10, 2018, which claims priority from U.S. Provisional PatentApplication Ser. No. 62/541,613, filed Aug. 4, 2017, and is also acontinuation-in-part of U.S. patent application Ser. No. 15/619,455,filed Jun. 10, 2017, now U.S. Pat. No. 9,851,966, issued Dec. 26, 2017,which is a continuation-in-part of U.S. patent application Ser. No.15/254,901, filed Sep. 1, 2016, now U.S. Pat. No. 9,729,583, issued Aug.8, 2017; which claims priority from: (1) U.S. Provisional PatentApplication Ser. No. 62/360,123, filed Jul. 8, 2016; (2) U.S.Provisional Patent Application Ser. No. 62/353,802, filed Jun. 23, 2016;and (3) U.S. Provisional Patent Application Ser. No. 62/348,695, filedJun. 10, 2016; the disclosures of all of the above-referenced patentapplications and patents are hereby incorporated herein by reference intheir entirety.

BACKGROUND

Over the past years, privacy and security policies, and relatedoperations have become increasingly important. Breaches in security,leading to the unauthorized access of personal data (which may includesensitive personal data) have become more frequent among companies andother organizations of all sizes. Such personal data may include, but isnot limited to, personally identifiable information (PII), which may beinformation that directly (or indirectly) identifies an individual orentity. Examples of PII include names, addresses, dates of birth, socialsecurity numbers, and biometric identifiers such as a person'sfingerprints or picture. Other personal data may include, for example,customers' Internet browsing habits, purchase history, or even theirpreferences (e.g., likes and dislikes, as provided or obtained throughsocial media).

Many organizations that obtain, use, and transfer personal data,including sensitive personal data, have begun to address these privacyand security issues. To manage personal data, many companies haveattempted to implement operational policies and processes that complywith legal and industry requirements. However, there is an increasingneed for improved systems and methods to manage personal data in amanner that complies with such policies.

SUMMARY

A computer-implemented method for prioritizing data subject accessrequests, according to particular embodiments, comprises: (1) receiving,by one or more processors, a data subject access request from arequestor comprising one or more request parameters; (2) applying, byone or more processors, a prioritization level to the received datasubject access request; (3) at least partially in response to receivingthe data subject access request, obtaining, by one or more processors,one or more pieces of metadata associated with a data subject of thedata subject access request; (4) determining, by one or more processors,whether the one or more pieces of metadata relate to a priority offulfilling the data subject access request; (5) in response todetermining that the obtained one or more pieces of metadata relate tothe priority of fulfilling the data subject access request, analyzing,by one or more processors, the one or more pieces of obtained metadatato determine whether the prioritization level of the data subject accessrequest should be adjusted; (6) in response to determining that theprioritization level of the data subject access request should beadjusted based on the obtained one or more pieces of metadata,adjusting, by one or more processors, the prioritization level of thedata subject access request for fulfillment of the data subject accessrequest; and (7) digitally storing, by one or more processors, theadjusted prioritization level of the data subject access request incomputer memory.

A computer-implemented method for prioritizing data subject accessrequests, in any embodiment described herein comprises: (1) receiving,by one or more processors, a data subject access request from arequestor; (2) at least partially in response to receiving the datasubject access request, obtaining, by one or more processors, one ormore pieces of metadata associated with a data subject of the datasubject access request, wherein the metadata is selected from a groupconsisting of: (A) a request type associated with the data subjectaccess request; (B) a location from which the data subject accessrequest is being made; (C) current sensitivities to world events; (D) astatus of the requestor issuing the data subject access request; and (E)a time in which the data subject access request was made; (3) analyzing,by one or more processors, the one or more pieces of obtained metadatato determine a prioritization level of the data subject access request;(4) determining, by one or more processors, the prioritization level ofthe data subject access request based at least in part on the one ormore pieces of obtained metadata; and (5) digitally storing, by one ormore processors, the prioritization level of the data subject accessrequest in computer memory.

A computer-implemented method for prioritizing data subject accessrequests, according to various embodiments, comprises: (1) receiving, byone or more processors, a data subject access request from a requestor;(2) validating, by one or more processors, an identity of the requestorby prompting the requestor to identify information associated with therequestor; (3) at least partially in response to receiving the datasubject access request, obtaining, by one or more processors, one ormore pieces of metadata associated with a data subject of the datasubject access request; (4) analyzing, by one or more processors, theone or more pieces of obtained metadata to determine a prioritizationlevel of the data subject access request; (5) determining, by one ormore processors, the prioritization level of the data subject accessrequest based at least in part on the one or more pieces of obtainedmetadata; and (6) digitally storing, by one or more processors, theprioritization level of the data subject access request in computermemory.

BRIEF DESCRIPTION OF THE DRAWINGS

Various embodiments of a data subject access request prioritizationsystem are described below. In the course of this description, referencewill be made to the accompanying drawings, which are not necessarilydrawn to scale, and wherein:

FIGS. 1-6 depict various exemplary screen displays and user interfacesthat a user of various embodiments of the system may encounter.

FIG. 7 depicts a data subject request processing and fulfillment systemaccording to particular embodiments.

FIG. 8 is a schematic diagram of a computer (such as the data modelgeneration server 110, or data model population server 120) that issuitable for use in various embodiments of the data subject requestprocessing and fulfillment system shown in FIG. 7.

FIGS. 9-49 are computer screen shots that demonstrate the operation ofvarious embodiments.

FIG. 50 is a flowchart showing an example of a processes performed by aData Subject Access Request Prioritization Module according to variousembodiments

FIG. 51 depicts an exemplary screen display of a data subject requestqueue that may be presented to indicate a prioritization of fulfillingdata subject access requests.

DETAILED DESCRIPTION

Various embodiments now will be described more fully hereinafter withreference to the accompanying drawings. It should be understood that theinvention may be embodied in many different forms and should not beconstrued as limited to the embodiments set forth herein. Rather, theseembodiments are provided so that this disclosure will be thorough andcomplete, and will fully convey the scope of the invention to thoseskilled in the art. Like numbers refer to like elements throughout.

Overview

In various embodiments, an organization, corporation, etc. may berequired to provide information requested by an individual for whom theorganization stores personal data. As a particular example, anorganization may be required to provide an individual with a listing of,for example: (1) any personal data that the organization is processingfor an individual, (2) an explanation of the categories of data beingprocessed and the purpose of such processing; (3) categories of thirdparties to whom the data may be disclosed; (4) etc. In particularembodiments, the system may prioritize the processing of data subjectaccess requests based on metadata related to the data subject accessrequest.

In various embodiments, a data subject access request prioritizationsystem may be implemented in the context of any suitable privacymanagement system that is configured to ensure compliance with one ormore legal or industry standards related to the collection and/orstorage of private information (e.g., such as personal data). In anyembodiment described herein, personal data may include, for example: (1)the name of a particular data subject (which may be a particularindividual); (2) the data subject's address; (3) the data subject'stelephone number; (4) the data subject's e-mail address; (5) the datasubject's social security number; (6) information associated with one ormore of the data subject's credit accounts (e.g., credit card numbers);(7) banking information for the data subject; (8) location data for thedata subject (e.g., their present or past location); (9) internet searchhistory for the data subject; and/or (10) any other suitable personalinformation, such as other personal information discussed herein. Inparticular embodiments, such personal data may include one or morecookies (e.g., where the individual is directly identifiable or may beidentifiable based at least in part on information stored in the one ormore cookies).

Various privacy and security policies (e.g., such as the EuropeanUnion's General Data Protection Regulation, and other such policies) mayprovide data subjects (e.g., individuals, organizations, or otherentities) with certain rights related to the data subject's personaldata that is collected, stored, or otherwise processed by anorganization. These rights may include, for example: (1) a right toobtain confirmation of whether a particular organization is processingtheir personal data; (2) a right to obtain information about the purposeof the processing (e.g., one or more reasons for which the personal datawas collected); (3) a right to obtain information about one or morecategories of data being processed (e.g., what type of personal data isbeing collected, stored, etc.); (4) a right to obtain information aboutone or more categories of recipients with whom their personal data maybe shared (e.g., both internally within the organization or externally);(5) a right to obtain information about a time period for which theirpersonal data will be stored (e.g., or one or more criteria used todetermine that time period); (6) a right to obtain a copy of anypersonal data being processed (e.g., a right to receive a copy of theirpersonal data in a commonly used, machine-readable format); (7) a rightto request erasure (e.g., the right to be forgotten), rectification(e.g., correction or deletion of inaccurate data), or restriction ofprocessing of their personal data; and (8) any other suitable rightsrelated to the collection, storage, and/or processing of their personaldata (e.g., which may be provided by law, policy, industry ororganizational practice, etc.). These rights may be asserted orrequested by a data subject as a data subject access request.

As may be understood in light of this disclosure, a particularorganization may undertake a plurality of different privacy campaigns,processing activities, etc. that involve the collection and storage ofpersonal data. In some embodiments, each of the plurality of differentprocessing activities may collect redundant data (e.g., may collect thesame personal data for a particular individual more than once), and maystore data and/or redundant data in one or more particular locations(e.g., on one or more different servers, in one or more differentdatabases, etc.). In this way, a particular organization may storepersonal data in a plurality of different locations which may includeone or more known and/or unknown locations. As such, complying withparticular privacy and security policies related to personal data (e.g.,such as responding to one or more requests by data subjects related totheir personal data) may be particularly difficult (e.g., in terms ofcost, time, etc.). In particular embodiments, the data subject accessrequest fulfillment system may utilize one or more data model generationand population techniques to create a centralized data map with whichthe system can identify personal data stored, collected, or processedfor a particular data subject, a reason for the processing, and anyother information related to the processing.

In particular embodiments, the data subject access request fulfillmentsystem is configured to: (1) receive a data subject access request froma data subject, the data subject access request comprising one or morerequests related to the one or more rights described above (e.g., arequest for a copy of the data subject's personal data, a requestregarding how long personal data associated with the data subject isbeing stored by the system, etc.); (2) process the request; and (3)fulfill the request based at least in part on one or more requestparameters.

FIGS. 1-2 depict exemplary screen displays that a user may view whensubmitting a data subject access request (e.g., exemplary userinterfaces for submitting a data subject access request). As shown inFIG. 1, a website associated with a particular organization may includea user-selectable indicia for submitting a privacy-related request. Auser desiring to make such a request may select the indicia in order toinitiate the data subject access request process.

FIG. 2 depicts an exemplary data subject access request form in both anunfilled and filled out state. As shown in this figure, the system mayprompt a user to provide information such as, for example: (1) what typeof requestor the user is (e.g., employee, customer, etc.); (2) what therequest involves (e.g., requesting info, opting out, deleting data,updating data, etc.); (3) first name; (4) last name; (5) email address;(6) telephone number; (7) home address; (8) one or more other pieces ofidentifying information; and/or (9) one or more details associated withthe request. As will be discussed more fully below, the system may beconfigured to utilize one or more pieces of information provided by thedata subject when processing and fulfilling the data subject accessrequest. This information may, for example, serve as metadata that thesystem uses in prioritizing such requests.

Various embodiments of a data subject access request prioritizationsystem are described more fully below.

Automatic Identity Validation Systems

In particular embodiments, when processing a data subject accessrequest, the system may be configured to verify an identity of the datasubject prior to processing the request (e.g., or as part of theprocessing step). In various embodiments, confirming the identity of thedata subject may, for example, limit a risk that a third-party or otherentity may gain unlawful or unconsented to access to the requestor'spersonal data. The system may, for example, limit processing andfulfillment of requests relating to a particular data subject torequests that are originated by (e.g., received from) the particulardata subject. When processing a data subject access request, the systemmay be configured to use all reasonable measures to verify the identityof the data subject who requests access (e.g., in particular in thecontext of online services and online identifiers). In particularembodiments, the system is configured to substantially automaticallyvalidate an identity of a data subject when processing the data subjectaccess request.

For example, in particular embodiments, the system may be configured tosubstantially automatically (e.g., automatically) authenticate and/orvalidate an identity of a data subject using any suitable technique.These techniques may include, for example: (1) one or more credit-basedand/or public- or private-information-based verification techniques; (2)one or more company verification techniques (e.g., in the case of abusiness-to-business data subject access request); (3) one or moretechniques involving integration with a company's employeeauthentication system; (4) one or more techniques involving a company's(e.g., organization's) consumer portal authentication process; (5) etc.Various exemplary techniques for authenticating a data subject arediscussed more fully below.

In particular embodiments, when authenticating a data subject (e.g.,validating the data subject's identity), the system may be configured toexecute particular identity confirmation steps, for example, byinterfacing with one or more external systems (e.g., one or morethird-party data aggregation systems). For example, the system, whenvalidating a data subject's identity, may begin by verifying that aperson with the data subject's name, address, social security number, orother identifying characteristic (e.g., which may have been provided bythe data subject as part of the data subject access request) actuallyexists. In various embodiments, the system is configured to interfacewith (e.g., transmit a search request to) one or more credit reportingagencies (e.g., Experian, Equifax, TransUnion, etc.) to confirm that aperson with one or more characteristics provided by the data subjectexists. The system may, for example, interface with such creditreporting agencies via a suitable plugin (e.g., software plugin).Additionally, there might be a verification on behalf of a trustedthird-party system (e.g., the controller).

In still other embodiments, the system may be configured to utilize oneor more other third-party systems (e.g., such as LexisNexis, IDology,RSA, etc.), which may, for example, compile utility and phone bill data,property deeds, rental agreement data, and other public records forvarious individuals. The system may be configured to interface with oneor more such third-party systems to confirm that a person with one ormore characteristics provided by the data subject exists.

After the step of confirming the existence of a person with the one ormore characteristics provided by the data subject, the system may beconfigured to confirm that the person making the data subject accessrequest is, in fact, the data subject. The system may, for example,verify that the requestor is the data subject by prompting the requestorto answer one or more knowledge-based authentication questions (e.g.,out-of-wallet questions). In particular embodiments, the system isconfigured to utilize one or more third-party services as a source ofsuch questions (e.g., any of the suitable third-party sources discussedimmediately above). The system may use third-party data from the one ormore third-party sources to generate one or more questions. These one ormore questions may include questions that a data subject should know ananswer to without knowing the question ahead of time (e.g., one or moreprevious addresses, a parent or spouse name and/or maiden name, etc.).

FIG. 3 depicts an exemplary identity verification questionnaire. As maybe understood from this figure, an identity verification questionnairemay include one or more questions whose responses include data that thesystem may derive from one or more credit agencies or other third-partydata aggregation services (e.g., such as previous street addresses,close associates, previous cities lived in, etc.). In particularembodiments, the system is configured to provide these one or morequestions to the data subject in response to receiving the data subjectaccess request. In other embodiments, the system is configured to promptthe data subject to provide responses to the one or more questions at alater time (e.g., during processing of the request). In particular otherembodiments, the system is configured to substantially automaticallycompare one or more pieces of information provided as part of the datasubject access request to one or more pieces of data received from athird-party data aggregation service in order to substantiallyautomatically verify the requestor's identity.

In still other embodiments, the system may be configured to prompt arequestor to provide one or more additional pieces of information inorder to validate the requestor's identity. This information mayinclude, for example: (1) at least a portion of the requestor's socialsecurity number (e.g., last four digits); (2) a name and/or place ofbirth of the requestor's father; (3) a name, maiden name, and/or placeof birth of the requestor's mother; and/or (4) any other informationwhich may be useful for confirming the requestor's identity (e.g., suchas information available on the requestor's birth certificate). In otherembodiments, the system may be configured to prompt the requestor toprovide authorization for the company to check the requestor's socialsecurity or other private records (e.g., credit check authorization,etc.) to obtain information that the system may use to confirm therequestor's identity. In other embodiments, the system may prompt theuser to provide one or more images (e.g., using a suitable mobilecomputing device) of an identifying document (e.g., a birth certificate,social security card, driver's license, etc.).

The system may, in response to a user providing one or more responsesthat matches information that the system receives from one or morethird-party data aggregators or through any other suitable background,credit, or other search, substantially automatically authenticate therequestor as the data subject. The system may then continue processingthe data subject's request, and ultimately fulfill their request.

In particular embodiments, such as embodiments in which the requestorincludes a business (e.g., as in a business to business data subjectaccess request), the system may be configured to authenticate therequesting business using one or more company verification techniques.These one or more company validation techniques may include, forexample, validating a vendor contract (e.g., between the requestingbusiness and the company receiving the data subject access request);receiving a matching token, code, or other unique identifier provided bythe company receiving the data subject access request to the requestingbusiness; receiving a matching file in possession of both the requestingbusiness and the company receiving the data subject access request;receiving a signed contract, certificate (e.g., digital or physical), orother document memorializing an association between the requestingbusiness and the company receiving the data subject access request;and/or any other suitable method of validating that a particular requestis actually made on behalf of the requesting business (e.g., byrequesting the requesting business to provide one or more pieces ofinformation, one or more files, one or more documents, etc. that mayonly be accessible to the requesting business).

In other embodiments, the system may be configured to authenticate arequest via integration with a company's employee or customer (e.g.,consumer) authentication process. For example, in response to receivinga data subject access request that indicates that the data subject is anemployee of the company receiving the data subject access request, thesystem may be configured to prompt the employee to login to thecompany's employee authentication system (e.g., Okta, Azure, AD, etc.)In this way, the system may be configured to authenticate the requestorbased at least in part on the requestor successfully logging into theauthentication system using the data subject's credentials. Similarly,in response to receiving a data subject access request that indicatesthat the data subject is a customer of the company receiving the datasubject access request, the system may be configured to prompt thecustomer to login to an account associated with the company (e.g., via aconsumer portal authentication process). In a particular example, thismay include, for example, an Apple ID (for data subject access requestsreceived by Apple). In this way, the system may be configured toauthenticate the requestor based at least in part on the requestorsuccessfully logging into the authentication system using the datasubject's credentials. In some embodiments, the system may be configuredto require the requestor to login using two-factor authentication orother suitable existing employee or consumer authentication process.

Data Subject Blacklist

In various embodiments, a particular organization may not be required torespond to a data subject access request that originates (e.g., isreceived from) a malicious requestor. A malicious requestor may include,for example: (1) a requestor (e.g., an individual) that submitsexcessive or redundant data subject access requests; (2) a group ofrequestors such as researchers, professors, students, NGOs, etc. thatsubmit a plurality of requests for reasons other than those reasonsprovided by policy, law, etc.; (3) a competitor of the company receivingthe data subject access request that is submitting such requests to tieup the company's resources unnecessarily; (4) a terrorist or otherorganization that may spam requests to disrupt the company's operationand response to valid requests; and/or (5) any other request that mayfall outside the scope of valid requests made for reasons proscribed bypublic policy, company policy, or law. In particular embodiments, thesystem is configured to maintain a blacklist of such maliciousrequestors.

In particular embodiments, the system is configured to track a source ofeach data subject access request and analyze each source to identifysources from which: (1) the company receives a large volume of requests;(2) the company receives a large number of repeat requests; (3) etc.These sources may include, for example: (1) one or more particular IPaddresses; (2) one or more particular domains; (3) one or moreparticular countries; (4) one or more particular institutions; (5) oneor more particular geographic regions; (6) etc. In various embodiments,in response to analyzing the sources of the requests, the system mayidentify one or more sources that may be malicious (e.g., are submittingexcessive requests).

In various embodiments, the system is configured to maintain a databaseof the identified one or more sources (e.g., in computer memory). Inparticular embodiments, the database may store a listing of identities,data sources, etc. that have been blacklisted (e.g., by the system). Inparticular embodiments, the system is configured to, in response toreceiving a new data subject access request, cross reference the requestwith the blacklist to determine if the requestor is on the blacklist oris making the request from a blacklisted source. The system may then, inresponse to determining that the requestor or source is blacklisted,substantially automatically reject the request. In particularembodiments, the blacklist cross-referencing step may be part of therequestor authentication (e.g., verification) discussed above. Invarious embodiments, the system may be configured to analyze requestdata on a company by company basis to generate a blacklist. In otherembodiments, the system may analyze global data (e.g., all datacollected for a plurality of companies that utilize the data subjectaccess request fulfillment system) to generate the blacklist.

In particular embodiments, the system may be configured to fulfill datasubject access requests for the purpose of providing a data subject withinformation regarding what data the company collects and for whatpurpose, for example, so the data subject can ensure that the company iscollecting data for lawful reasons. As such, the system may beconfigured to identify requestors and other sources of data requeststhat are made for other reasons (e.g., one or more reasons that wouldnot obligate the company to respond to the request). These reasons mayinclude, for example, malicious or other reasons such as: (1) researchby an academic institution by one or more students or professors; (2)anticompetitive requests by one or more competitors; (3) requests bydisgruntled former employees for nefarious reasons; (4) etc.

In particular embodiments, the system may, for example, maintain adatabase (e.g., in computer memory) of former employees. In otherembodiments, the system may, for example: (1) identify a plurality of IPaddresses associated with a particular entity (e.g., academicorganization, competitor, etc.); and (2) substantially automaticallyreject a data subject access request that originates from the pluralityof IP addresses. In such embodiments, the system may be configured toautomatically add such identified IP addresses and/or domains to theblacklist.

In still other embodiments, the system is configured to maintain alisting of blacklisted names of particular individuals. These mayinclude, for example, one or more individuals identified (e.g., by anorganization or other entity) as submitting malicious data subjectaccess requests).

FIG. 4 depicts a queue of pending data subject access requests. As shownin this figure, the first three listed data subject access requests arenew and require verification before processing and fulfillment canbegin. As shown in this figure, a user (e.g., such as a privacy officeror other privacy controller) may select a particular request, and selectan indicia for verifying the request. The user may also optionallyselect to reject the request. FIG. 5 depicts an authentication windowthat enables the user to authenticate a particular request. In variousembodiments, the user may provide an explanation of why the user isauthenticating the request (e.g., because the requestor successfullycompleted on or more out-of-wallet questions or for any other suitablereason). The user may further submit one or more attachments to supportthe verification. In this way, the system may be configured to documentthat the authentication process was performed for each request (e.g., incase there was an issue with improperly fulfilling a request, thecompany could show that they are following procedures to prevent suchimproper processing). In other embodiments, the system may enable theuser to provide similar support when rejecting a request (e.g., becausethe requestor was blacklisted, made excessive requests, etc.).

Data Subject Access Request Fulfillment Cost Determination

In various embodiments, as may be understood in light of thisdisclosure, fulfilling a data subject access request may be particularlycostly. In some embodiments, a company may store data regarding aparticular data subject in multiple different locations for a pluralityof different reasons as part of a plurality of different processing andother business activities. For example, a particular data subject may beboth a customer and an employee of a particular company or organization.Accordingly, in some embodiments, fulfilling a data subject accessrequest for a particular data subject may involve a plurality ofdifferent information technology (IT) professionals in a plurality ofdifferent departments of a particular company or organization. As such,it may be useful to determine a cost of a particular data subject accessrequest (e.g., particularly because, in some cases, a data subject isentitled to a response to their data subject access request as a matterof right at no charge).

In particular embodiments, in response to receiving a data subjectaccess request, the system may be configured to: (1) assign the requestto at least one privacy team member; (2) identify one or more IT teamsrequired to fulfill the request (e.g., one or more IT teams associatedwith one or more business units that may store personal data related tothe request); (3) delegate one or more subtasks of the request to eachof the one or more IT teams; (4) receive one or more time logs from eachindividual involved in the processing and fulfillment of the datasubject access request; (5) calculate an effective rate of eachindividual's time (e.g., based at least in part on the individual'ssalary, bonus, benefits, chair cost, etc.); (6) calculate an effectivecost of fulfilling the data subject access request based at least inpart on the one or more time logs and effective rate of each of theindividual's time; and (7) apply an adjustment to the calculatedeffective cost that accounts for one or more external factors (e.g.,overhead, etc.) in order to calculate a cost of fulfilling the datasubject access request.

In particular embodiments, the system is configured to substantiallyautomatically track an amount of time spent by each individual involvedin the processing and fulfillment of the data subject access request.The system may, for example, automatically track an amount of timebetween each individual opening and closing a ticket assigned to them aspart of their role in processing or fulfilling the data subject accessrequest. In other embodiments, the system may determine the time spentbased on an amount of time provided by each respective individual (e.g.,the individual may track their own time and submit it to the system).

In various embodiments, the system is configured to measure a cost ofeach particular data subject access request received, and analyze one ormore trends in costs of, for example: (1) data subject access requestsover time; (2) related data subject access requests; (3) etc. Forexample, the system may be configured to track and analyze cost andtime-to-process trends for one or more social groups, one or morepolitical groups, one or more class action groups, etc. In particular,the system may be configured to identify a particular group from whichthe system receives particularly costly data subject access request(e.g., former and/or current employees, members of a particular socialgroup, members of a particular political group, etc.).

In particular embodiments, the system may be configured to utilize datasubject access request cost data when processing, assigning, and/orfulfilling future data subject access requests (e.g., from a particularidentified group, individual, etc.). For example, the system may beconfigured to prioritize requests that are expected to be less costlyand time-consuming (e.g., based on past cost data) over requestsidentified as being likely more expensive. Alternatively, the system mayprioritize more costly and time-consuming requests over less costly onesin the interest of ensuring that the system is able to respond to eachrequest in a reasonable amount of time (e.g., within a time required bylaw, such as a thirty day period, or any other suitable time period).

Customer Satisfaction Integration with Data Subject Access Requests

In various embodiments, the system may be configured to collect customersatisfaction data, for example: (1) as part of a data subject accessrequest submission form; (2) when providing one or more results of adata subject access request to the data subject; or (3) at any othersuitable time. In various embodiments, the customer satisfaction datamay be collected in the form of a suitable survey, free-form responsequestionnaire, or other suitable satisfaction data collection format(e.g., thumbs up vs. thumbs down, etc.).

FIG. 6 depicts an exemplary customer satisfaction survey that may beincluded as part of a data subject access request form, provided alongwith the results of a data subject access request, provided in one ormore messages confirming receipt of a data subject access request, etc.As shown in the figure, the customer satisfaction survey may relate tohow likely a customer (e.g., a data subject) is to recommend the company(e.g., to which the data subject has submitted the request) to a friend(e.g., or colleague). In the example shown in FIG. 6, the satisfactionsurvey may relate to a Net Promoter score (NPS), which may indicate aloyalty of a company's customer relationships. Generally speaking, theNet Promoter Score may measure a loyalty that exists between a providerand a consumer. In various embodiments, the provider may include acompany, employer, or any other entity. In particular embodiments, theconsumer may include a customer, employee, or other respondent to an NPSsurvey.

In particular embodiments, the question depicted in FIG. 6 is theprimary question utilized in calculating a Net Promoter Score (e.g.,“how likely is it that you would recommend our company/product/serviceto a friend or colleague?”). In particular embodiments, the question ispresented with responses ranging from 0 (not at all likely) to 10(extremely likely). In particular embodiments, the question may includeany other suitable scale. As may be understood from FIG. 6, the systemmay be configured to assign particular categories to particular ratingson the 10 point scale. The system may be configured to track and storeresponses provided by consumers and calculate an overall NPS score forthe provider. The system may be further configured to generate a visualrepresentation of the NPS score, including a total number of responsesreceived for each particular score and category as shown in FIG. 6.

In various embodiments, the system may be configured to measure datarelated to any other suitable customer satisfaction method (e.g., inaddition to NPS). By integrating a customer satisfaction survey with thedata subject access request process, the system may increase a number ofconsumers that provide one or more responses to the customersatisfaction survey. In particular embodiments, the system is configuredto require the requestor to respond to the customer satisfaction surveyprior to submitting the data subject access request.

Exemplary Technical Platforms

As will be appreciated by one skilled in the relevant field, the presentinvention may be, for example, embodied as a computer system, a method,or a computer program product. Accordingly, various embodiments may takethe form of an entirely hardware embodiment, an entirely softwareembodiment, or an embodiment combining software and hardware aspects.Furthermore, particular embodiments may take the form of a computerprogram product stored on a computer-readable storage medium havingcomputer-readable instructions (e.g., software) embodied in the storagemedium. Various embodiments may take the form of web-implementedcomputer software. Any suitable computer-readable storage medium may beutilized including, for example, hard disks, compact disks, DVDs,optical storage devices, and/or magnetic storage devices.

Various embodiments are described below with reference to block diagramsand flowchart illustrations of methods, apparatuses (e.g., systems), andcomputer program products. It should be understood that each block ofthe block diagrams and flowchart illustrations, and combinations ofblocks in the block diagrams and flowchart illustrations, respectively,can be implemented by a computer executing computer programinstructions. These computer program instructions may be loaded onto ageneral-purpose computer, special-purpose computer, or otherprogrammable data processing apparatus to produce a machine, such thatthe instructions which execute on the computer or other programmabledata processing apparatus to create means for implementing the functionsspecified in the flowchart block or blocks.

These computer program instructions may also be stored in acomputer-readable memory that can direct a computer or otherprogrammable data processing apparatus to function in a particularmanner such that the instructions stored in the computer-readable memoryproduce an article of manufacture that is configured for implementingthe function specified in the flowchart block or blocks. The computerprogram instructions may also be loaded onto a computer or otherprogrammable data processing apparatus to cause a series of operationalsteps to be performed on the computer or other programmable apparatus toproduce a computer implemented process such that the instructions thatexecute on the computer or other programmable apparatus provide stepsfor implementing the functions specified in the flowchart block orblocks.

Accordingly, blocks of the block diagrams and flowchart illustrationssupport combinations of mechanisms for performing the specifiedfunctions, combinations of steps for performing the specified functions,and program instructions for performing the specified functions. Itshould also be understood that each block of the block diagrams andflowchart illustrations, and combinations of blocks in the blockdiagrams and flowchart illustrations, can be implemented by specialpurpose hardware-based computer systems that perform the specifiedfunctions or steps, or combinations of special purpose hardware andother hardware executing appropriate computer instructions.

Example System Architecture

FIG. 7 is a block diagram of a data subject access request processingand fulfillment system 100 according to a particular embodiment. Invarious embodiments, the data subject access request processing andfulfillment system is part of a privacy compliance system (also referredto as a privacy management system), or other system, which may, forexample, be associated with a particular organization and be configuredto aid in compliance with one or more legal or industry regulationsrelated to the collection and storage of personal data. I

As may be understood from FIG. 7, the data subject access requestprocessing and fulfillment system 100 includes one or more computernetworks 115, a Data Model Generation Server 110, a Data ModelPopulation Server 120, an Intelligent Identity Scanning Server 130, Oneor More Databases 140 or other data structures, one or more remotecomputing devices 150 (e.g., a desktop computer, laptop computer, tabletcomputer, smartphone, etc.), and One or More Third Party Servers 160. Inparticular embodiments, the one or more computer networks 115 facilitatecommunication between the Data Model Generation Server 110, Data ModelPopulation Server 120, Intelligent Identity Scanning Server 130, One orMore Databases 140, one or more remote computing devices 150 (e.g., adesktop computer, laptop computer, tablet computer, smartphone, etc.),One or More Third Party Servers 160, and DSAR Processing and FulfillmentServer 170. Although in the embodiment shown in FIG. 1, the Data ModelGeneration Server 110, Data Model Population Server 120, IntelligentIdentity Scanning Server 130, One or More Databases 140, one or moreremote computing devices 150 (e.g., a desktop computer, laptop computer,tablet computer, smartphone, etc.), and One or More Third Party Servers160, and DSAR Processing and Fulfillment Server 170 are shown asseparate servers, it should be understood that in other embodiments, oneor more of these servers and/or computing devices may comprise a singleserver, a plurality of servers, one or more cloud-based servers, or anyother suitable configuration.

The one or more computer networks 115 may include any of a variety oftypes of wired or wireless computer networks such as the Internet, aprivate intranet, a public switch telephone network (PSTN), or any othertype of network. The communication link between The Intelligent IdentityScanning Server 130 and the One or More Third Party Servers 160 may be,for example, implemented via a Local Area Network (LAN) or via theInternet. In other embodiments, the One or More Databases 140 may bestored either fully or partially on any suitable server or combinationof servers described herein.

FIG. 8 illustrates a diagrammatic representation of a computer 200 thatcan be used within the data subject access request processing andfulfillment system 100, for example, as a client computer (e.g., one ormore remote computing devices 130 shown in FIG. 7), or as a servercomputer (e.g., Data Model Generation Server 110 shown in FIG. 7). Inparticular embodiments, the computer 200 may be suitable for use as acomputer within the context of the data subject access requestprocessing and fulfillment system 100 that is configured to generate adata model and map one or more relationships between one or more piecesof data that make up the model.

In particular embodiments, the computer 200 may be connected (e.g.,networked) to other computers in a LAN, an intranet, an extranet, and/orthe Internet. As noted above, the computer 200 may operate in thecapacity of a server or a client computer in a client-server networkenvironment, or as a peer computer in a peer-to-peer (or distributed)network environment. The Computer 200 may be a personal computer (PC), atablet PC, a set-top box (STB), a Personal Digital Assistant (PDA), acellular telephone, a web appliance, a server, a network router, aswitch or bridge, or any other computer capable of executing a set ofinstructions (sequential or otherwise) that specify actions to be takenby that computer. Further, while only a single computer is illustrated,the term “computer” shall also be taken to include any collection ofcomputers that individually or jointly execute a set (or multiple sets)of instructions to perform any one or more of the methodologiesdiscussed herein.

An exemplary computer 200 includes a processing device 202, a mainmemory 204 (e.g., read-only memory (ROM), flash memory, dynamic randomaccess memory (DRAM) such as synchronous DRAM (SDRAM) or Rambus DRAM(RDRAM), etc.), static memory 206 (e.g., flash memory, static randomaccess memory (SRAM), etc.), and a data storage device 218, whichcommunicate with each other via a bus 232.

The processing device 202 represents one or more general-purposeprocessing devices such as a microprocessor, a central processing unit,or the like. More particularly, the processing device 202 may be acomplex instruction set computing (CISC) microprocessor, reducedinstruction set computing (RISC) microprocessor, very long instructionword (VLIW) microprocessor, or processor implementing other instructionsets, or processors implementing a combination of instruction sets. Theprocessing device 202 may also be one or more special-purpose processingdevices such as an application specific integrated circuit (ASIC), afield programmable gate array (FPGA), a digital signal processor (DSP),network processor, or the like. The processing device 202 may beconfigured to execute processing logic 226 for performing variousoperations and steps discussed herein.

The computer 120 may further include a network interface device 208. Thecomputer 200 also may include a video display unit 210 (e.g., a liquidcrystal display (LCD) or a cathode ray tube (CRT)), an alphanumericinput device 212 (e.g., a keyboard), a cursor control device 214 (e.g.,a mouse), and a signal generation device 216 (e.g., a speaker).

The data storage device 218 may include a non-transitorycomputer-accessible storage medium 230 (also known as a non-transitorycomputer-readable storage medium or a non-transitory computer-readablemedium) on which is stored one or more sets of instructions (e.g.,software instructions 222) embodying any one or more of themethodologies or functions described herein. The software instructions222 may also reside, completely or at least partially, within mainmemory 204 and/or within processing device 202 during execution thereofby computer 200—main memory 204 and processing device 202 alsoconstituting computer-accessible storage media. The softwareinstructions 222 may further be transmitted or received over a network115 via network interface device 208.

While the computer-accessible storage medium 230 is shown in anexemplary embodiment to be a single medium, the term“computer-accessible storage medium” should be understood to include asingle medium or multiple media (e.g., a centralized or distributeddatabase, and/or associated caches and servers) that store the one ormore sets of instructions. The term “computer-accessible storage medium”should also be understood to include any medium that is capable ofstoring, encoding or carrying a set of instructions for execution by thecomputer and that cause the computer to perform any one or more of themethodologies of the present invention. The term “computer-accessiblestorage medium” should accordingly be understood to include, but not belimited to, solid-state memories, optical and magnetic media, etc.

Systems for Managing Data Subject Access Requests

In various embodiments, the system may include a ticket managementsystem and/or other systems for managing data subject access requests.Various embodiments of such systems are described below.

Overview

Ticket management systems, according to various embodiments, are adaptedto receive data subject access requests (DSAR's) from particular datasubjects, and to facilitate the timely processing of valid DSAR's by anappropriate respondent. In particular embodiments, the ticket managementsystem receives DSAR's via one or more webforms that each may beaccessed via an appropriate link on a respective web page. In otherembodiments, the system may receive DSAR's through any other suitablemechanism, such as via a computer software application (e.g., amessaging application such as Slack, Twitter), or through entry by arepresentative who may receive the information, for example, viasuitable paper forms or over the phone.

The ticket management system may include a webform creation tool that isadapted to allow a user to create customized webforms for receivingDSAR's from various different data subject types and for routing therequests to appropriate individuals for processing. The webform creationtool may, for example, allow the user to specify the language that theform will be displayed in, what particular information is to berequested for the data subject and/or provided by the data subject, whoany DSAR's that are received via the webform will be routed to, etc. Inparticular embodiments, after the user completes their design of thewebform, the webform creation tool generates code for the webform thatmay be cut and then pasted into a particular web page.

The system may be further adapted to facilitate processing of DSAR'sthat are received via the webforms, or any other suitable mechanism. Forexample, the ticket management system may be adapted to execute one ormore of the following steps for each particular DSAR received via thewebforms (or other suitable mechanism) described above: (1) beforeprocessing the DSAR, confirm that the DSAR request was actuallysubmitted by the particular data subject of the DSAR (or, for example,by an individual authorized to make the DSAR request on the datasubject's behalf, such as a parent, guardian, power-of-attorney holder,etc.)—any suitable method may be used to confirm the identity of theentity/individual submitting the DSAR—for example, if the systemreceives the DSAR via a third-party computer system, the system mayvalidate authentication via API secret, or by requiring a copy of one ormore particular legal documents (e.g., a particular contract between twoparticular entities)—the system may validate the identity of anindividual by, for example, requiring the individual (e.g., datasubject) to provide particular account credentials, by requiring theindividual to provide particular out-of-wallet information, throughbiometric scanning of the individual (e.g., finger or retinal scan), orvia any other suitable identity verification technique; (2) if the DSARwas not submitted by the particular data subject, deny the request; (3)if the DSAR was submitted by the particular data subject, advance theprocessing of the DSAR; (4) route the DSAR to the correct individual(s)or groups internally for handling; (5) facilitate the assignment of theDSAR to one or more other individuals for handling of one or moreportions of the DSAR; and/or (6) facilitate the suspension of the datasubject access request. In particular embodiments, the system mayperform any one or more of the above steps automatically. The systemthen generates a receipt for the DSAR request that the user can use fora transactional record of their submitted request.

In particular embodiments, the ticket management system may be adaptedto generate a graphical user interface (e.g., a DSAR request-processingdashboard) that is adapted to allow a user (e.g., a privacy officer ofan organization that is receiving the DSAR) to monitor the progress ofany the DSAR requests. The GUI interface may display, for each DSAR, forexample, an indication of how much time is left (e.g., quantified indays and/or hours) before a legal and/or internal deadline to fulfillthe request. The system may also display, for each DSAR, a respectiveuser-selectable indicium that, when selected, may facilitate one or moreof the following: (1) verification of the request; (2) assignment of therequest to another individual; (3) requesting an extension to fulfillthe request; (4) rejection of the request; or (5) suspension of therequest.

As noted immediately above, and elsewhere in this application, inparticular embodiments, any one or more of the above steps may beexecuted by the system automatically. As a particular example, thesystem may be adapted to automatically verify the identity of the DSARrequestor and then automatically fulfill the DSAR request by, forexample, obtaining the requested information via a suitable data modeland communicating the information to the requestor. As anotherparticular example, the system may be configured to automatically routethe DSAR to the correct individual for handling based at least in parton one or more pieces of information provided (e.g., in the webform).

Operation of Example Implementation

FIGS. 9-49 are screen shots that demonstrate the operation of aparticular embodiment. FIGS. 9-12 show a graphical user interface (GUI)of an example webform construction tool. FIG. 9 shows a user working todesign a webform called “Web_form_1”. As may be understood from thevertical menu shown on the left-hand side of the screen, the webformconstruction tool allows users to design a webform by: (1) specifyingthe details of the form (via the “Form Details” tab); (2) defining thefields that will be displayed on the webform (via the “Webform Fields”tab); (3) defining the styling of the webform (via the “Form Styling”tab); and (4) defining various settings associated with the webform (viathe “Settings” tab). As shown in FIGS. 10-12, the user may also specifytext to be displayed on the webform (e.g., via a “Form Text” tab).

FIG. 10 shows that, by selecting the “Form Details” tab, the user maydefine which answers a requestor will be able to specify on the webformin response to prompts for information regarding what type of individualthey are (customer, employee, etc.) and what type of request they aremaking via the webform. Example request types include: (1) a request forall personal data that an organization is processing for the datasubject (a copy of the personal data in a commonly used,machine-readable format); (2) a request for all such personal data to bedeleted; (3) a request to update personal data that the organization isstoring for the data subject; (4) a request to opt out of having theorganization use the individual's personal information in one or moreparticular ways (e.g., per the organization's standard businesspractices); (5) file a complaint; and/or (6) other.

FIG. 11 shows that, by selecting the “Settings” tab, the user mayspecify various system settings, such as whether Captcha will be used toverify that information is being entered by a human, rather than acomputer.

FIG. 12 shows that, by selecting the Form Styling tab, the user mayspecify the styling of the webform. The styling may include, forexample: (1) a header logo; (2) header height; (3) header color; (4)body text color; (5) body text size; (6) form label color; (7) buttoncolor; (8) button text color; (9) footer text color; (10) footer textsize; and/or any other suitable styling related to the webform.

In other embodiments, the system is configured to enable a user tospecify, when configuring a new webform, what individual at a particularorganization (e.g., company) will be responsible for responding torequests made via the webform. The system may, for example, enable theuser to define a specific default sub-organization (e.g., within theorganization) responsible for responding to DSAR's submitted via the newwebform. As such, the system may be configured to automatically route anew DSAR made via the new webform to the appropriate sub-organizationfor processing and fulfillment. In various embodiments, the system isconfigured to route one or more various aspects of the DSAR to one ormore different sub-organizations within the organization.

In still other embodiments, the system is configured to enable a usergenerating webforms to assign multiple webforms to multiple differentsuborganizations within an organization. For example, an organizationcalled ACME, Inc. may have a website for each of a plurality ofdifferent brands (e.g., sub-organizations) under which ACME sellsproducts (e.g., UNICORN Brand T-shirts, GRIPP Brand Jeans, etc.). As maybe understood in light of this disclosure, each website for each of theparticular brands may include an associated webform for submittingDSAR's. Each respective webform may be configured to route a DSAR madevia its associated brand website to a particular sub-organization withinACME for handling DSAR's related to the brand.

As noted above, after the user uses the webform construction tool todesign a particular webform for use on a particular web page, thewebform construction tool generates code (e.g., HTML code) that may bepasted into the particular web page to run the designed webform page.

FIG. 13 shows the privacy webpage of a company (e.g., the ACMEcorporation). As shown in this figure, a requestor may submit a DSAR byselecting a “Submit a Privacy Related Request” button on the web page.

FIG. 14 shows a webform that is displayed after a requestor selects the“Submit a Privacy Related Request” button on the privacy webpage of FIG.13. As may be understood from this figure, the requestor may completethe webform by specifying which type of user they are, and what type ofrequest they are making. The webform also asks the requestor to provideenough personal information to confirm their identity (e.g., and fulfillthe request). As shown in this figure, the system may prompt a usersubmitting a DSAR to provide information such as, for example: (1) whattype of requestor the user is (e.g., employee, customer, etc.); (2) whatthe request involves (e.g., requesting info, opting out, deleting data,updating data, etc.); (3) first name; (4) last name; (5) email address;(6) telephone number; (7) home address; (8) one or more other pieces ofidentifying information; and/or (9) one or more details associated withthe request. FIG. 15 shows an example populated version of the webform.

As shown in FIG. 16, after a requestor completes the webform and selectsa “submit” indicia, the system displays a message to the requestorindicating that their DSAR has been successfully submitted. The systemalso displays a Request ID associated with the request. In response tothe requestor successfully submitting the request, the system may alsosend an email to the requestor confirming the request. An example of asuitable confirmation email is shown in FIG. 17.

In various embodiments, the system includes a dashboard that may be usedby various individuals within an organization (e.g., one or more privacyofficers of an organization) to manage multiple DSAR requests. Asdiscussed above, the dashboard may display DSAR's submitted,respectively, to a single organization, any of multiple differentsub-organizations (divisions, departments, subsidiaries etc.) of aparticular organization, and/or any of multiple independentorganizations. For example, the dashboard may display DSAR's that weresubmitted from a parent organization and from the parent organization'sU.S. and European subsidiaries. This may be advantageous, for example,because it may allow an organization to manage all DSAR requests of allof its sub-organizations centrally.

FIGS. 18-29, 31-33, 35-40, and 45-47 depict various exampleuser-interface screens of a DSAR request-management dashboard. As may beunderstood from FIG. 18, after an appropriate user (e.g., a privacyofficer associated with a particular organization) logs into the system,the system may display a Data Subject Request Queue that may, forexample, display a listing of all data subject access requests that theappropriate individual has been designated to process. As shown in FIG.18, each data subject access request may be represented by a respectiverow of information that includes: (1) an ID number for the request; (2)the name of the data subject who has submitted the request; (3) thestatus of the request; (4) the number of days that are left to respondto the request (e.g., according to applicable laws and/or internalprocedures); (5) an indication as to whether the deadline to respond tothe request has been extended; (6) a creation date of the request; (7)an indication of the type of requestor that submitted the request(customer, employee, etc.); (8) the name of the individual who has beenassigned to process the request (e.g., the respondent). This screen mayalso include selectable “Edit” and “Filter” buttons that respectivelyfacilitate acting on and filtering the various requests displayed on thepage.

As shown in FIG. 19, in response to a respondent selecting the editbutton, the system displays a dropdown menu allowing the respondent toselect between taking the following actions: (1) verify the request; (2)assign the request to another individual; (3) request an extension; (4)reject the request; or (5) suspend the request.

FIGS. 20 and 21 show a message that the system displays to therespondent in response to the respondent selecting the “verify” option.As shown in this figure, the system prompts the respondent to indicatewhether they are sure that they wish to authenticate the request. Thesystem also presents an input field where the respondent can enter textto be displayed to the requestor along with a request for the requestorto provide information verifying that they are the data subjectassociated with the request. After the respondent populates the inputfield, they may submit the request by selecting a “Submit” button.

In other embodiments, the input field may enable the respondent toprovide one or more supporting reasons for a decision, by therespondent, to authenticate the request. The respondent may also uploadone or more supporting documents (such as an attachment). The supportingdocuments or information may include, for example, one or more documentsutilized in confirming the requestor's identity, etc.

In response to the respondent selecting the Submit button, the systemchanges the status of the request to “In Progress” and also changes thecolor of the request's status from orange to blue (or to any othersuitable color)—see FIG. 22. The system also generates and sends amessage (e.g., an electronic or paper message) to the requestor askingthem to submit information verifying the request. The message mayinclude the text that the respondent entered in the text box of FIGS. 20and 21.

As shown in FIGS. 23-25, in response to a respondent selecting the“Edit” button and then selecting the “Assign” indicia from the displayeddropdown menu, the system displays a Request Assignment interface thatallows a respondent to indicate who the request should be assigned to.For example, the respondent may indicate that they will be handling therequest, or assign the request to another suitable individual, who may,for example, then be designated as the respondent for the request. Ifthe respondent assigns the request to another individual, they may alsoprovide an email address or other correspondence information for theindividual. The Request Assignment interface includes a comment box forallowing a respondent to add a message to the individual that theassignment will be assigned to regarding the assignment. In response tothe respondent selecting the “Assign” button, the system assigns therequest to the designated individual for handling. If the request hasbeen assigned to another individual, the system automatically generatesand sends a message (e.g., an electronic message such as an email or SMSmessage) to the individual informing them of the assignment.

As shown in FIGS. 26-28, in response to a respondent selecting the“Edit” button and then selecting the “Reject” indicia from the displayeddropdown menu, the system displays a Reject Request interface. Thisinterface includes a comment box for allowing a respondent to add amessage to the requestor as to why the request was rejected. In responseto the respondent selecting the “Submit” button, the system changes thestatus of the request to “Rejected” and changes the color of therequest's status indicator to red (See FIG. 29). The system may alsoautomatically generate a message (e.g., an electronic or paper message)to the requestor notifying them that their request has been rejected anddisplaying the text that the respondent entered into the Reject Requestinterface of FIG. 28. An example of such a message is shown in FIG. 30.

As shown in FIGS. 31-32, in response to a respondent selecting the“Edit” button and then selecting the “Request Extension” indicia fromthe displayed dropdown menu, the system displays a Request Extensioninterface. This includes a text box for allowing a user to indicate thenumber of days for which they would like to extend the current deadlinefor responding to the request. For example, the dialog box of FIG. 32shows the respondent requesting that the current deadline be extended by90 days. In response to the respondent entering a desired extensionduration and selecting the “Submit” button, the system updates thedeadline in the system's memory (e.g., in an appropriate data structure)to reflect the extension. For instance, in the example of FIG. 32, thesystem extends the deadline to be 90 days later than the currentdeadline. As shown in FIG. 33, the system also updates the “Days Left toRespond” field within the Data Subject Request Queue to reflect theextension (e.g., from 2 days from the current date to 92 days from thecurrent date). As shown in FIG. 34, the system may also generate anappropriate message (e.g., an electronic or paper message) to therequestor indicating that the request has been delayed. This message mayprovide a reason for the delay and/or an anticipated updated completiondate for the request.

In particular embodiments, the system may include logic forautomatically determining whether a requested extension complies withone or more applicable laws or internal policies and, in response,either automatically grant or reject the requested extension. Forexample, if the maximum allowable time for replying to a particularrequest is 90 days under the controlling laws and the respondentrequests an extension that would result in the fulfillment of therequest 91 or more days from the date that the request was submitted,the system may automatically reject the extension request. In variousembodiments, the system may also communicate, to the respondent (e.g.,via a suitable electronic message or text display on a system userinterface) an explanation as to why the extension request was denied,and/or a maximum amount of time (e.g., a maximum number of days) thatthe deadline may be extended under the applicable laws or policies. Invarious embodiments, if the system determines that the requestedextension is permissible under the applicable laws and/or policies, thesystem may automatically grant the extension. In other embodiments, thesystem may be configured to automatically modify a length of therequested extension to conform with one or more applicable laws and/orpolicies.

As shown in FIGS. 35-40, a respondent may obtain additional detailsregarding a particular request by selecting (e.g., clicking on) therequest on the Data Subject Request Queue screen. For example, FIG. 36shows a Data Subject Request Details screen that the system displays inresponse to a respondent selecting the “Donald Blair” request on theuser interface screen of FIG. 35. As shown in FIG. 36, the Data SubjectRequest Details screen shows all correspondence between the organizationand the requesting individual regarding the particular data subjectaccess request. As may be understood from FIG. 37, when a respondentselects a particular correspondence (e.g., email), the system displaysthe correspondence to the respondent for review or other processing.

As shown in FIG. 38, in various embodiments, the system may provide aselectable “Reply” indicia that allows the respondent to reply toparticular correspondence from an individual. As may be understood fromthis figure, in response to the respondent selecting the “Reply”indicia, the system may display a dropdown menu of various standardreplies. For example, the dropdown menu may provide the option ofgenerating a reply to the requestor indicating that the request has beenrejected, is pending, has been extended, or that the request has beencompleted.

As shown in FIG. 39, in response to the respondent selecting “Reply asCompleted”, the system may display a draft email to the requestorexplaining that the request has been completed. The respondent may thenedit this email and send the correspondence (e.g., via email) to therequestor by selecting a “Send as Complete” indicia. As shown in FIG.40, the system may, in response, display an indicator adjacent thecorrespondence indicating that the correspondence included a replyindicating that the request was complete. This may be useful in allowingindividuals to understand the contents of the correspondence withouthaving to open it.

FIG. 41 shows an example email automatically generated by the system inresponse to the respondent selecting “Reply as Completed” on the screenshown in FIG. 38. As shown in FIG. 41, the correspondence may include asecure link that the requestor may select to access the data that wasrequested in the DSAR. In particular embodiments, the link is a link toa secure website, such as the website shown in FIG. 42, that providesaccess to the requested data (e.g., by allowing a user to download a.pdf file, or other suitable file, that includes the requested data). Asshown in FIG. 42, the website may require multiple pieces of data toverify that the requestor is permitted to access the site. For example,in order to access the website, the requestor may be required to provideboth the unique ID number of the request, and an authentication token,which the system may send to the user via email—See FIGS. 43 and 44.

FIGS. 45-49 are computer screen shots that depict additional userinterfaces according to various embodiments.

Additional Concepts

Automated Data Subject Verification

In various embodiments, before a data subject request can be processed,the data subject's identity needs to be verified. In variousembodiments, the system provides a mechanism to automatically detect thetype of authentication required for a particular data subject based onthe type of Data Subject Access Request being made and automaticallyissues a request to the data subject to verify their identity againstthat form of identification. For example, a subject rights request mightonly require two types of authentication, but a deletion request mayrequire four types of data to verify authentication. The system mayautomatically detect which is type of authentication is required basedon the DSAR and send an appropriate request to the data subject toverify their identity.

Intelligent Prioritization of DSAR's

In various embodiments, the system may be adapted to prioritize theprocessing of DSAR's based on metadata about the data subject of theDSAR. For example, the system may be adapted for: (1) in response toreceiving a DSAR, obtaining metadata regarding the data subject; (2)using the metadata to determine whether a priority of the DSAR should beadjusted based on the obtained metadata; and (3) in response todetermining that the priority of the DSAR should be adjusted based onthe obtained metadata, adjusting the priority of the DSAR.

Examples of metadata that may be used to determine whether to adjust thepriority of a particular DSAR include: (1) the type of request, (2) thelocation from which the request is being made, (3) current sensitivitiesto world events, (4) a status of the requestor (e.g., especially loyalcustomer, important client, competitor, etc.), or (5) any other suitablemetadata.

In various embodiments, in response to the system determining that thepriority of a particular DSAR should be elevated, the system mayautomatically adjust the deadline for responding to the DSAR. Forexample, the system may update the deadline in the system's memoryand/or modify the “Days Left to Respond” field (See FIG. 19) to includea fewer number of days left to respond to the request. Alternatively, orin addition, the system may use other techniques to convey to arespondent that the request should be expedited (e.g., change the colorof the request, send a message to the respondent that they shouldprocess the request before non-prioritized requests, etc.)

In various embodiments, in response to the system determining that thepriority of a particular DSAR should be lowered, the system mayautomatically adjust the deadline for responding to the DSAR by addingto the number of days left to respond to the request. In otherembodiments, the system may be configured to prioritize more demandingrequests (e.g., requests that may require more effort and/or resourcesto process), for example, to ensure that the requests can be fulfilledwithin legally defined deadlines or timelines.

Various embodiments of a data subject access request prioritizationsystem are described more fully below. In particular embodiments, a DataSubject Access Request Prioritization Module 5000 is configured toreceive a data subject access request, obtain one or more pieces ofmetadata associated with the data subject access request, analyze theone or more pieces of metadata associated with the data subject accessrequest to determine or adjust a prioritization level of the datasubject access request, and digitally store the determined or adjustedprioritization level of the data subject access request in computermemory.

Turning to FIG. 50, when executing the Data Subject Access RequestPrioritization Module 5000, the system begins, at step 5010, byreceiving a data subject access request. In various embodiments, thesystem receives the request via a suitable web form. In certainembodiments, the request comprises a particular request to perform oneor more actions with any personal data stored by a particularorganization regarding the requestor. For example, in some embodiments,the request may include a request to view one or more pieces of personaldata stored by the system regarding the requestor. In other embodiments,the request may include a request to delete one or more pieces ofpersonal data stored by the system regarding the requestor. In stillother embodiments, the request may include a request to update one ormore pieces of personal data stored by the system regarding therequestor. Additionally, as described above, data subjects may beentitled to certain rights related to the data subject's personal datathat is collected, stored, or otherwise processed by an organization,and the rights may be asserted or requested by a data subject as a datasubject access request. The organization may fulfill the data subjectaccess request. To fulfill the data subject access request, the systemcan retrieve the identified one or more pieces of personal dataassociated with the data subject to perform the requested operation tothe identified one or more pieces of personal data associated with thedata subject.

The system may further be configured to process the request byvalidating the identity of the requestor. The system may be configuredto substantially automatically (e.g., automatically) authenticate and/orvalidate an identity of a data subject using any suitable technique.These techniques may include, for example: (1) one or more credit-basedand/or public- or private-information-based verification techniques; (2)one or more company verification techniques (e.g., in the case of abusiness-to-business data subject access request); (3) one or moretechniques involving integration with a company's employeeauthentication system; (4) one or more techniques involving a company's(e.g., organization's) consumer portal authentication process; (5) etc.

In particular embodiments, when authenticating a data subject (e.g.,validating the data subject's identity), the system may be configured toexecute particular identity confirmation steps, for example, byinterfacing with one or more external systems (e.g., one or morethird-party data aggregation systems). For example, the system, whenvalidating a data subject's identity, may begin by verifying that aperson with the data subject's name, address, social security number, orother identifying characteristic (e.g., which may have been provided bythe data subject as part of the data subject access request) actuallyexists. In still other embodiments, the system may be configured toutilize one or more other third-party systems (e.g., such as LexisNexis,IDology, RSA, etc.), which may, for example, compile utility and phonebill data, property deeds, rental agreement data, and other publicrecords for various individuals. After confirming the existence of aperson with the one or more characteristics provided by the datasubject, the system may be configured to confirm that the person makingthe data subject access request is, in fact, the data subject.

In various embodiments, the system may apply a prioritization level toeach data subject access request. The prioritization level can be usedto attribute an urgency, importance, and/or sensitivity in fulfillingeach particular data subject access request. Additionally, theprioritization level may be used to place the data subject accessrequests in an order of fulfillment (e.g., in a data processing queuefor fulfillment). The prioritization level applied to the data subjectaccess request after the system receives the data subject access requestcan be based on the data included in the data subject access requestitself, which may include, for example, an identity of the data subject,an identity of the particular organization receiving the data subjectaccess request, a requested deadline for receiving fulfillment of thedata subject access request, among others. In some implementations, theprioritization level can be two levels (e.g., “standard” and “urgent” or“standard” and “sensitive”), and in some implementations, the system caninclude three or more different prioritization levels (e.g., “high,”“medium,” and “low).

Continuing to step 5020, the system is configured to obtain one or morepieces of metadata associated with the data subject access request. Theone or more pieces of metadata describe additional information relatedto the data subject access request (e.g., describe information about thedata subject of the data subject access request), and may include amultitude of additional information. Examples of metadata that mayrelate to the priority of a particular data subject access request caninclude, for example: (1) a request type associated with the datasubject access request; (2) a location from which the data subjectaccess request is being made; (3) current sensitivities to world events(e.g., a war occurring in a country where a particular organization hasa server that stores data subject's information); (4) a status of therequestor issuing the data subject access request; and (5) a time inwhich the data subject access request was made. The metadata related tothe request type identifies what the requestor is requesting from theparticular organization. For example, the request type can be a requestto advise the requestor of the personal data that the organization hasstored related to the requestor (e.g., a subject's rights request) or arequest to delete one or more pieces of personal data stored by theparticular organization regarding the requestor (e.g., a data subjectdeletion request).

In particular embodiments, the metadata may include, for example: (1)the requestor's IP address (e.g., or other location data); (2) therequestor's MAC address; (3) one or more regulations that apply to therequest, etc. In particular embodiments, the metadata that determinesthe prioritization of the request may include the type of request (e.g.,a request for data, a request to delete data, and/or a request tocorrect data). Requests for deletion and production of data may, forexample, be prioritized ahead of data correction requests. In otherembodiments, the system may prioritize requests that have a legal basis(e.g., any suitable request under the GDPR) over requests to which adata subject may not be legally entitled (e.g., but that theorganization may still fulfil, but at a lower priority level behindother more pressing requests).

In various embodiments, the metadata may be provided to the system aspart of, or along with, the data subject access request. However, insome embodiments, the metadata may be provided substantiallyautomatically (e.g., automatically) subsequently to the system receivingthe data subject access request, or an individual of the particularorganization (e.g., a privacy officer) may manually request the one ormore pieces of metadata subsequently to receiving the data subjectaccess request. In some embodiments, the system may obtain one or morepieces of metadata from a third party (e.g., a web browser identifyingcurrent events in a particular location). Additionally, in someimplementations, the data subject access request and/or metadata can beprovided to the system via a secure terminal or secure link between acomputer system that includes the metadata (e.g., the computer system ofthe requestor) and the system to prevent interception of the data orunwarranted access to the additional information. Additionally, the dataof the data subject access request and/or metadata may be encrypted forthe transmission of the data.

At step 5030, the system is configured to analyze the one or more piecesof obtained metadata to determine a prioritization level of the datasubject access request. The system may analyze the one or more pieces ofmetadata to identify information related to an urgency for fulfillingthe particular data subject access request.

In some implementations, a prioritization level is applied to the datasubject access request prior to the system receiving and/or analyzingthe one or more pieces of metadata, as described above. This initialprioritization level may be applied based on data provided in the datasubject access request (e.g., an identification of the requestor). Thesystem may obtain the one or more pieces of metadata, as describedabove, and determine whether the one or more pieces of metadata relateto a priority of fulfilling the data subject access request. The systemmay perform the determination by analyzing the contents of the one ormore pieces of metadata for information related to, for example: (1) arequest type associated with the data subject access request; (2) alocation from which the data subject access request is being made; (3)current sensitivities to world events (e.g., a war occurring in acountry where a particular organization has a server that stores datasubject's information); (4) a status of the requestor issuing the datasubject access request (e.g., customer); and (5) a time in which thedata subject access request was made.

In response to the system determining that the obtained one or morepieces of metadata relate to the priority of fulfilling the data subjectaccess request, the system may analyze the metadata to determine whetherthe prioritization level of the data subject access request should beadjusted. The system may analyze the content of the metadata that wasdetermined to be related to the prioritization level of the data subjectaccess request.

In various embodiments, to determine a prioritization of a data subjectaccess request, the system may analyze the content of metadataassociated with the data subject access request to determine a locationfrom which the data subject assess request is being made (e.g., ageographical location, a jurisdiction, a country, a city, and/or acontinent from which the data subject access request is being made). Forexample, the system may be configured to analyze the content of themetadata to determine a location of the requestor that issued the datasubject access request. In another example, the system may be configuredto analyze the content of the metadata to determine a location of thedata subject associated with the data subject access request. Based onsuch a location (e.g., of the requestor and/or of the associated datasubject), the system may be configured to determine one or moreregulations applicable to the data subject access request. Then, basedat least in part on the determined applicable one or more regulations,the system may set the respective prioritization level of the datasubject access request.

In an example, the system may be configured to determine both thelocation of the requestor that issued a particular data subject accessrequest and the location of the data subject associated with theparticular data subject access request. The system may be configured tothen determine whether those locations are the same location (e.g., arein the same jurisdiction, the same country, and/or the same continent,etc.). If the requestor and the data subject are in the same location(or are approximately the same location), the system may be configuredto determine one or more applicable regulations and determine arespective prioritization level of the data subject access request basedat least in part on the determined location. If the requestor and thedata subject associated with the particular data subject access requestare not in the same location (e.g., are in different jurisdictions,different countries, and/or different continents, etc.), the system maybe configured to base the determination of the respective prioritizationlevel of the data subject access request, at least in part, on the factthat the particular data subject and the particular requestor are indifferent locations. The system may also, or instead, be configureddetermine one or more applicable regulations for each of the differentlocations and use those respective determined one or more regulations todetermine the respective prioritization level of the particular datasubject access request based at least in part on the respectivedetermined one or more regulations.

For example, if one of the one or more pieces of metadata relate to alocation from which the data subject access request is being made andthe content of the metadata identifies that the location from which therequest is being made is a different continent than the location thedata servers that store the personal data for the particularorganization (receiving the data subject access request), then thesystem may determine that the urgency and sensitivity of this particularmetadata necessitates an adjustment to the prioritization level of thedata subject access request. Specifically, the system may determine thatthe data transmission and rules involving storage of personal data indifferent continents indicates a greater risk and more attentionrequired in fulfilling the data subject access request. In continuingthe above example, if the content of the metadata identified that thelocation from which the request is being made is the same continentwhere the data servers that store the personal data for the particularorganization are located, then the system may determine that anadjustment to the prioritization level of the data subject accessrequest is not necessitated.

In response to determining that the prioritization level of the datasubject access request should be adjusted based on the obtained one ormore pieces of metadata, the system may adjust the prioritization levelof the data subject access request for fulfillment. As described above,the system may adjust the prioritization level based on the analyzedcontent of the metadata that was determined to be related to theprioritization level of the data subject access request. When the systemdetermines that the urgency, importance, and/or sensitivity of the oneor more pieces of obtained metadata necessitate an adjustment to theprioritization level, the system can increase the prioritization levelof the data subject access request from, for example, a “standard”prioritization level to an “urgent” prioritization level, or a “normal”prioritization level to a “high” prioritization level. Additionally, thesystem may determine that the content of the obtained metadata reducesthe urgency, importance, and/or sensitivity of data subject accessrequest, and the system can decrease the prioritization level of thedata subject access request from, for example, a “urgent” prioritizationlevel to an “standard” prioritization level, or a “normal”prioritization level to a “low” prioritization level.

In various embodiments, the prioritization level may be stored by thesystem and presented (e.g., via a user interface to the privacy officerof the organization) as a prioritization indicator associated with thedata subject access request to show the prioritization level of the datasubject access request has been adjusted. For example, the system canstore a listing of data subject access requests, and a column within auser interface presentation of the listing of data subject accessrequests can provide the prioritization indicator that could present onecolor (e.g., yellow) for a “standard” prioritization level and adifferent color (e.g., red) for an “urgent” prioritization level.

Further, in some embodiments, in response to adjusting theprioritization level of the data subject access request, the system maymodify a completion date for fulfillment of the data subject accessrequest (e.g., the completion data may be stored in a database of thesystem and presented in a user interface to a privacy officer of theorganization). For example, when the system decreases the prioritizationlevel of the data subject access request, the system may move thecompletion date back by modifying the completion date to a modifiedcompletion date that is a later date than the initial completion date(e.g., modifying the completion date from Dec. 29, 2018 to Dec. 31,2018). Likewise, in some embodiments, when the system increases theprioritization level of the data subject access request, the system maymove the completion date forward by modifying the completion date to amodified completion date that is an earlier date than the initialcompletion date (e.g., modifying the completion date from Dec. 29, 2018to Dec. 27, 2018). In some embodiments, the completion date can be shownas “Days Left to Respond,” so the system may calculate the days leftfrom a current date to the completion date, and the present the numberof days left until the completion date from the current date.

In various embodiments, in response to adjusting the prioritizationlevel of the data subject access request, the system may generate aprioritization message (e.g., email or other type of electroniccommunication) to indicate that the prioritization level of the datasubject access request has been adjusted. Further, the system mayelectronically communicate the prioritization message to at least oneprivacy team member that is assigned to fulfill the data subject accessrequest (e.g., a privacy officer for the particular organization).

In some embodiments, a prioritization level is first applied to the datasubject access request subsequently to the system analyzing the one ormore pieces of metadata associated with the data subject access request.In such embodiments, the system may analyze the one or more pieces ofmetadata, and in response determine a prioritization level for the datasubject access request (i.e., the prioritization level is not adjustedbased on the analysis of the one or more pieces of metadata because theprioritization is first determined after the one or more pieces ofmetadata are analyzed).

Further, at step 5040, the system is configured to digitally store theprioritization level of the data subject access request in computermemory. Additionally, in embodiments where the prioritization level isadjusted, the system is configured to digitally store the adjustedprioritization level of the data subject access request in computermemory. The system may access the stored prioritization level (oradjusted prioritization level) for each of a plurality of data subjectaccess request and place the data subject access requests in an order offulfillment (e.g., in a data processing queue for fulfillment).

Data Subject Access Request Prioritization User Experience

FIG. 51 depicts an exemplary user interface that may be included toassist in prioritizing the fulfillment of the data subject accessrequests. For example, the user interface can be presented to theprivacy officer assigned to fulfill the data subject access requests. Asshown in the Figure, the user interface may present a data subjectaccess request queue for fulfillment, which may include a prioritizationcolumn along with additional columns (e.g., ID column, a name ofrequestor column, etc.) for each data subject access request to provideinformation for the particular organization to fulfill the data subjectaccess request. In the exemplary user interface, a prioritizationindicator is included for each data subject access request where theprioritization indicators include prioritization levels of “Low,”“Normal,” and “Urgent.” The privacy officer or other individual within aparticular organization responsible for fulfilling the data subjectaccess request may arrange and organize their fulfillment of the datasubject access requests based on the prioritization level provided. Thedata subject access requests may, for example, be sorted based on theprioritization levels (e.g., where the data subject access requests withan “Urgent” prioritization level are grouped at the top of the datasubject request queue followed by the data subject access requests witha “Normal” prioritization level, and then the data subject accessrequests with a “Low” prioritization level) or the other columns.Additionally, the data subject access requests may be filtered based onthe prioritization levels (e.g., where the data subject access requestswith an “Urgent” prioritization level are only shown in the data subjectrequest queue).

Automatic Deletion of Data Subject Records Based on Detected Systems

In particular embodiments, in response a data subject submitting arequest to delete their personal data from an organization's systems,the system may: (1) automatically determine where the data subject'spersonal data is stored; and (2) in response to determining the locationof the data (which may be on multiple computing systems), automaticallyfacilitate the deletion of the data subject's personal data from thevarious systems (e.g., by automatically assigning a plurality of tasksto delete data across multiple business systems to effectively deletethe data subject's personal data from the systems). In particularembodiments, the step of facilitating the deletion may comprise, forexample: (1) overwriting the data in memory; (2) marking the data foroverwrite; (2) marking the data as free (e.g., and deleting a directoryentry associated with the data); and/or (3) any other suitable techniquefor deleting the personal data. In particular embodiments, as part ofthis process, the system uses an appropriate data model (see discussionabove) to efficiently determine where all of the data subject's personaldata is stored.

Automatic Determination of Business Processes that Increase Chance ofDeletion Requests

In various embodiments, the system is adapted to store, in memory, a logof DSAR actions. The system may also store, in memory, additionalinformation regarding the data subjects of each of the requests. Thesystem may use this information, for example, to determine whichbusiness processes are most commonly associated with a data subjectsubmitting a request to have their personal information deleted from theorganization's systems. The organization may then use this informationto revise the identified business processes in an effort to reduce thenumber of deletion requests issued by data subjects associated with thebusiness processes.

As a particular example, the system may analyze stored information todetermine that a high number (e.g., 15%) of all participants in acompany's loyalty program submit requests to have their personalinformation deleted from the company's systems. In response to makingthis determination, the system may issue an electronic alert to anappropriate individual (e.g., a privacy officer of the company),informing them of the high rate of members of the company's loyaltyprogram issuing personal data delete requests. This alert may prompt theindividual to research the issue and try to resolve it.

Conclusion

Although embodiments above are described in reference to various privacycompliance monitoring systems, it should be understood that variousaspects of the system described above may be applicable to otherprivacy-related systems, or to other types of systems, in general.

While this specification contains many specific embodiment details,these should not be construed as limitations on the scope of anyinvention or of what may be claimed, but rather as descriptions offeatures that may be specific to particular embodiments of particularinventions. Certain features that are described in this specification inthe context of separate embodiments may also be implemented incombination in a single embodiment. Conversely, various features thatare described in the context of a single embodiment may also beimplemented in multiple embodiments separately or in any suitablesub-combination. Moreover, although features may be described above asacting in certain combinations and even initially claimed as such, oneor more features from a claimed combination may in some cases be excisedfrom the combination, and the claimed combination may be directed to asub-combination or variation of a sub-combination.

Similarly, while operations are depicted in the drawings in a particularorder, this should not be understood as requiring that such operationsbe performed in the particular order shown or in sequential order, orthat all illustrated operations be performed, to achieve desirableresults. In certain circumstances, multitasking and parallel processingmay be advantageous. Moreover, the separation of various systemcomponents in the embodiments described above should not be understoodas requiring such separation in all embodiments, and it should beunderstood that the described program components and systems maygenerally be integrated together in a single software product orpackaged into multiple software products.

Many modifications and other embodiments of the invention will come tomind to one skilled in the art to which this invention pertains havingthe benefit of the teachings presented in the foregoing descriptions andthe associated drawings. Therefore, it is to be understood that theinvention is not to be limited to the specific embodiments disclosed andthat modifications and other embodiments are intended to be includedwithin the scope of the appended claims. Although specific terms areemployed herein, they are used in a generic and descriptive sense onlyand not for the purposes of limitation.

What is claimed is:
 1. A computer-implemented data processing method forprioritizing data subject access requests, the method comprising:receiving from a requestor, by one or more processors, a data subjectaccess request comprising one or more request parameters; applying, bythe one or more processors, a prioritization level to the data subjectaccess request based at least in part on the one or more requestparameters; determining, by the one or more processors, one or morepieces of metadata associated with the data subject access request;determining, by the one or more processors based on the one or morepieces of metadata, a location from which the data subject accessrequest is being made; determining, by the one or more processors,whether the location from which the data subject access request is beingmade relates to a priority of fulfilling the data subject accessrequest; in response to determining that the location from which thedata subject access request is being made relates to the priority offulfilling the data subject access request, analyzing, by the one ormore processors, the location from which the data subject access requestis being made to determine whether the prioritization level of the datasubject access request should be adjusted; in response to determiningthat the prioritization level of the data subject access request shouldbe adjusted based on the location from which the data subject accessrequest is being made, adjusting, by the one or more processors, theprioritization level of the data subject access request for fulfillmentof the data subject access request, wherein adjusting the prioritizationlevel of the data subject access request comprises: modifying acompletion date for fulfillment of the data subject access request basedon the adjusted prioritization level of the data subject access request,and updating a prioritization indicator associated with the data subjectaccess request to indicate that the prioritization level of the datasubject access request has been adjusted; and digitally storing, by theone or more processors, the adjusted prioritization level of the datasubject access request in computer memory.
 2. The computer-implementeddata processing method of claim 1, wherein determining the location fromwhich the data subject access request is being made comprises:determining an IP address based, at least in part, on the one or morepieces of metadata; and determining the location from which the datasubject access request is being made based, at least in part, on the IPaddress.
 3. The computer-implemented data processing method of claim 1,further comprising determining, based at least in part on the locationfrom which the data subject access request is being made, one or moreregulations that apply to the data subject access request.
 4. Thecomputer-implemented data processing method of claim 1, whereindetermining the one or more pieces of metadata associated with the datasubject access request comprises: requesting the one or more one or morepieces of metadata from the requestor issuing the data subject accessrequest; and receiving the one or more one or more pieces of metadatafrom the requestor issuing the data subject access request.
 5. Thecomputer-implemented data processing method of claim 1, wherein theprioritization level is one of a first pre-determined prioritizationlevel and a second pre-determined prioritization level.
 6. Thecomputer-implemented data processing method of claim 1, furthercomprising determining, based at least in part on the one or more piecesof metadata, one or more of: a request type associated with the datasubject access request, a status of the requestor issuing the datasubject access request, or a time in which the data subject accessrequest was made.
 7. The computer-implemented data processing method ofclaim 1, wherein: adjusting the prioritization level comprises adjustingthe prioritization level to decrease the prioritization level of thedata subject access request; and modifying the completion date forfulfillment of the data subject access request comprises modifying thecompletion date to a modified completion date that is a later date thanthe completion date.
 8. The computer-implemented data processing methodof claim 1, wherein: adjusting the prioritization level comprisesadjusting the prioritization level to increase the prioritization levelof the data subject access request; and modifying the completion datefor fulfillment of the data subject access request comprises modifyingthe completion date to a modified completion date that is an earlierdate than the completion date.
 9. The computer-implemented dataprocessing method of claim 8, further comprising: generating aprioritization message to indicate that the prioritization level of thedata subject access request has been adjusted; and providing, viaelectronic communication, the prioritization message to at least oneprivacy team member that is assigned to fulfill the data subject accessrequest.
 10. The computer-implemented data processing method of claim 1,wherein determining the one or more pieces of metadata associated withthe data subject access request comprises: generating a secure linkbetween the one or more processors and a computing device associatedwith the requestor issuing the data subject access request to preventoutside access to the one or more pieces of metadata; receiving, via thesecure link, the one or more pieces of metadata; and digitally storing,in computer memory, the one or more pieces of metadata in associationwith the data subject access request.
 11. The computer-implemented dataprocessing method of claim 10, further comprising: generating aprioritization message to indicate that the prioritization level of thedata subject access request has been adjusted; and providing, viaelectronic communication, the prioritization message to at least oneprivacy team member that is assigned to fulfill the data subject accessrequest.
 12. A computer-implemented data processing method forprioritizing data subject access requests, the method comprising:receiving, by one or more processors, a data subject access request froma requestor; validating, by the one or more processors, an identity ofthe requestor by prompting the requestor to identify informationassociated with the requestor; at least partially in response tovalidating the identity of the requestor, determining, by the one ormore processors, one or more pieces of metadata associated with the datasubject access request; determining, by the one or more processors basedon the one or more pieces of metadata, a location from which the datasubject access request is being made; analyzing, by the one or moreprocessors, the location from which the data subject access request isbeing made, wherein analyzing the location from which the data subjectaccess request is being made comprises determining whether the locationfrom which the data subject access request is being made impacts apriority of fulfilling the data subject access request; determining, bythe one or more processors, the prioritization level of the data subjectaccess request based at least in part on the analyzed location fromwhich the data subject access request is being made; and digitallystoring, by the one or more processors, the prioritization level of thedata subject access request in computer memory.
 13. Thecomputer-implemented data processing method of claim 12, furthercomprising: determining, based on the one or more pieces of metadata, alocation of a data subject associated with the data subject accessrequest, wherein determining the prioritization level of the datasubject access request is further based at least in part on the locationof the data subject associated with the data subject access request. 14.The computer-implemented data processing method of claim 12, furthercomprising: determining, based at least in part on the one or morepieces of metadata, that a location of a data subject associated withthe data subject access request is a first geographical location that isdistinct from a second geographical location of the location from whichthe data subject access request is being made, wherein determining theprioritization level of the data subject access request is further basedat least in part on determining that the first geographical location isdistinct from the second geographical location.
 15. Thecomputer-implemented data processing method of claim 12, whereindetermining the one or more pieces of metadata further comprises:generating a secure link between the one or more processors and acomputing device associated with the requestor issuing the data subjectaccess request to prevent outside access to the one or more pieces ofmetadata; receiving, via the secure link, the one or more pieces ofmetadata; and digitally storing one or more pieces of metadata inassociation with the data subject access request.
 16. Thecomputer-implemented data processing method of claim 12, whereindetermining the location from which the data subject access request isbeing made comprises: determining an IP address based on the one or morepieces of metadata; and determining the location from which the datasubject access request is being made based, at least in part, on the IPaddress.
 17. The computer-implemented data processing method of claim12, further comprising: determining, based at least in part on thelocation from which the data subject access request is being made, oneor more laws or regulations that apply to the data subject accessrequest, wherein: determining the prioritization level of the datasubject access request is further based at least in part on the one ormore laws or regulations.
 18. A computer-implemented data processingmethod for prioritizing data subject access requests, the methodcomprising: receiving, by one or more processors, a data subject accessrequest from a requestor; at least partially in response to receivingthe data subject access request, obtaining, by the one or moreprocessors, one or more pieces of metadata associated with the datasubject access request; determining, by the one or more processors basedat least in part on the one or more pieces of metadata, a location fromwhich the data subject access request is being made; analyzing, by theone or more processors, the location from which the data subject accessrequest is being made to determine whether the location from which thedata subject access request is being made impacts a priority offulfilling the data subject access request; in response to determiningthat the location from which the data subject access request is beingmade impacts a priority of fulfilling the data subject access request,determining a prioritization level of the data subject access requestbased at least in part on the location from which the data subjectaccess request is being made; and digitally storing, by the one or moreprocessors, the prioritization level of the data subject access requestin computer memory.
 19. The computer-implemented data processing methodof claim 18, wherein obtaining the one or more pieces of metadatacomprises: requesting the one or more one or more pieces of metadatafrom the requestor issuing the data subject access request; andreceiving the one or more one or more pieces of metadata from therequestor issuing the data subject access request.
 20. Thecomputer-implemented data processing method of claim 18, whereinobtaining the one or more pieces of metadata comprises: generating asecure link between the one or more processors and a computing deviceassociated with the requestor issuing the data subject access request toprevent outside access to the one or more pieces of metadata; receiving,via the secure link, the one or more pieces of metadata; and digitallystoring one or more pieces of metadata in association with the datasubject access request.
 21. The computer-implemented data processingmethod of claim 18, wherein determining the location from which the datasubject access request is being made comprises: determining an IPaddress based on the one or more pieces of metadata; and determining thelocation from which the data subject access request is being made basedat least in part on the IP address.
 22. The computer-implemented dataprocessing method of claim 18, wherein the one or more pieces ofmetadata comprise information related to one or more of: a request typeassociated with the data subject access request, a status of therequestor issuing the data subject access request, or a time in whichthe data subject access request was made.
 23. The computer-implementeddata processing method of claim 18, further comprising determining,based on the location from which the data subject access request isbeing made, one or more laws or regulations that apply to the datasubject access request; and determining a prioritization level of thedata subject access request comprises determining the prioritizationlevel based, at least in part on the one or more laws or regulations.24. The computer-implemented data processing method of claim 18, whereinthe prioritization level is one of a first predetermined prioritizationlevel and a second predetermined prioritization level.
 25. Thecomputer-implemented data processing method of claim 18, wherein:fulfilling the data subject access request comprises identifying one ormore pieces of personal data associated with a data subject associatedwith the data subject access request; and identifying the one or morepieces of personal data associated with the data subject comprisesscanning one or more data inventories for the one or more pieces ofpersonal data.
 26. A non-transitory computer-readable medium storingcomputer-executable instructions for: receiving a data subject accessrequest from a requestor; at least partially in response to receivingthe data subject access request, obtaining one or more pieces ofmetadata associated with the data subject access request; determining,based on the one or more pieces of metadata, a geographical locationfrom which the data subject access request is being made; determining,based on the one or more pieces of metadata, a geographical location ofa data subject associated with the data subject access request;determining, based on the one or more pieces of metadata, that thegeographical location from which the data subject access request isbeing made is distinct from the geographical location of the datasubject associated with the data subject access request; analyzing thegeographical location from which the data subject access request isbeing made and the geographical location of the data subject associatedwith the data subject access request to determine whether thegeographical location from which the data subject access request isbeing made being distinct from the geographical location of the datasubject associated with the data subject access request impacts apriority of fulfilling the data subject access request; at leastpartially in response to determining that the geographical location fromwhich the data subject access request is being made being distinct fromthe geographical location of the data subject associated with the datasubject access request impacts a priority of fulfilling the data subjectaccess request, determining a prioritization level of the data subjectaccess request based, at least in part, on the geographical locationfrom which the data subject access request is being made being distinctfrom the geographical location of the data subject associated with thedata subject access request; and digitally storing the prioritizationlevel of the data subject access request in computer memory.